ey-global-tax-policy-outlook-for-2015

United States
• There is a desire to reform the US tax system to increase
US competitiveness relative to some of its trading partners
that have lower corporate income tax rates and territorial
tax systems. However, ideological differences have hindered
efforts to advance such debate. Republicans will control
the legislative agenda in 2015, and those who lead the
tax-writing committees support tax reform. Possible
as both parties see opportunities for economic growth,
including via business tax reform. However, overcoming the
political hurdles to craft the details of such legislation will be
challenging.
• An increased focus on the taxes multinational companies
pay and where they pay them is also shaping US tax
policy. Policymakers and the media have also focused on
“inversions,” in which a parent company of a US corporate
group reincorporates in a non-US jurisdiction. The US
transactions, and legislative proposals have also been
announced and introduced, though not enacted.
•
been particularly vocal on several of the actions, among
them those related to the digital economy, taxation of
controlled foreign companies (CFCs) and country-by-country
reporting.
2.2 Fiscal consolidation vs. stimulus
• Headline CIT rate
• Interest deductibility
• Hybrid mismatches
• Treatment of losses
• Capital gains tax
•
•
• Controlled foreign companies (CFCs)
• Thin capitalization
• Transfer pricing changes
•
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